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2014-2015 Federal Student Aid Application Comments Tracking Summary 

Comment Status Resolution 

1) # 76 on SAR has a misspelled word: received Resolved. Question 76 on the paper SAR has been 

corrected and now reads:

76. Parent received Supplemental

Nutrition Assistance Program (SNAP)?

2) I am adamantly opposed to changing the parental 

information on the 2014-15 FAFSA. Same sex marriage is not 

federally recognized. Most states still define marriage as 

between one man and one woman. Our federal government 

is discriminating against gay couples and refuses to offer the 

same fundamental rights that heterosexual couples have. 

However, now not only are we denying them marriage, but 

we are also asking them to include their partner's financial 

information on the FAFSA. Children of same sex couples 

cannot have both parents listed on their birth certificate, but 

now we are forcing them to list both parents' information on 

the FAFSA. We are double hurting these families. In most 

circumstances (especially for middle class families), this will 

greatly increase the student's EFC. Until same sex marriage is 

recognized by the federal government and until they receive 

the same rights and benefits as all other Americans, I am 

adamantly opposed to requiring same sex couples who live 

together to include both parents' income on the FAFSA.

Resolved. The Department of Education is currently 

reviewing the recent Supreme Court decision 

on the Defense of Marriage Act and the scope 

of its impact on the Free Application for Federal 

Student Aid (FAFSA). In general, the 2014-2015 

FAFSA will include guidance explaining that 

marriage includes a legal marriage of persons of 

the opposite sex as well as legal marriages of 

persons of the same sex in jurisdictions where it 

is allowed. Further guidance is forthcoming.

3) I would suggest the following change to the second sentence 

of the instructions for the "Step Four (Parent)" section at the 

top of page 6 of the draft paper FAFSA:

"Grandparents, foster parents, legal guardians, aunts and 

uncles, and partners of biological or adoptive parents are not 

considered parents on this form unless they have legally 

Resolved. These instruction for Step Four (Parent) have 

been revised. 

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.
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Comment Status Resolution 

adopted you."

I believe that this change will provide needed clarification 

concerning the change to who is considered a parent on the 

FAFSA.

4) 1. On page 6 of the draft FAFSA Q#80 asks if parents 

completed their IRS tax return or another tax return listed in 

Q81? - What if the two parents answers differ? for example 

one parent filed and one parent did not

2. On page 6 of the draft FAFSA Q#83 asks if your parents 

have filed or will file a 1040; were they eligible to file a 1040A 

or 1040EZ? what if the two parents answers differ? for 

example one parent had to file a 1040 and the other was 

eligible to file a 1040A

3. I think you should provide a separate field for a suffix (Jr, 

III, etc.) instead of just having a space between the last name 

and the suffix in the last name field as many systems pull 

ISIRS into their system based on last name only and thus get 

hung up in suspense b/c of this. This slows down the 

processing of aid for those students.

1. Resolved

2. Resolved.

3. Resolved. 

No Change.

1. Help text is being added to FAFSA on the 

Web to clarify exactly what parents and 

students should enter in this situation.

Additionally, text in the “Using Your Tax 

Return” section on page 1 of the paper FAFSA

has been revised.

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.

2. Refer to response above. 

3. Spacing limitations prevent this from being 

included on the paper FAFSA. Each year, third

party software providers are given Federal 

Student Aid (FSA) specifications for Institutional 

Student Information Record (ISIR) processing.

5) Question 28 on the 2014-2015 FAFSA asks "Will you have 

your first bachelor’s degree before July 1, 2014?"

However, students earning their bachelor's degree after July 

1, 2014 but during the 2014-2015 year would answer "no" to 

this question, and could and most likely have/will receive(d) 

Pell grant monies they are not eligible for. If they earn their 

degree in Dec 2014 then transfer and if the school they 

transfer to does not require college transcripts or the student 

Resolved. The Department of Education will update the 

existing guidance on FAFSA on the Web to 

clarify this limitation on federal student aid.
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Comment Status Resolution 

fails to submit them the student would unintentionally be 

paid pell grants. I can't imagine a student receiving Pell grant 

at the same school after receiving their degree in the Fall but 

that could happen as well.

Could an additional question be added asking what month 

the student will earn their bachelor's degree if they are to 

earn it before June 30, 2015? Then schools can avoid 

unintentionally paying these students Pell grants.

6) Additional detail should be collected in regards to the 

household size; number in college; spouse name and SSN (if 

both parents information is needed, why not spouse info.; 

SNAP benefits (name of person in household receiving 

benefits); child support paid - listing all detail needed during 

verification.

All of these can be easily accomplished by adding pop-up lists 

when they complete the field on FOTW. If these lists are 

completed, then the need for verification worksheets would 

no longer be needed. One of our biggest areas where 

students/parents make errors is on the verificaiton worksheet 

list of household members months after completing the 

FAFSA - if it's completed at the same time, there would be no 

errors.

(example: 4 in the household - must enter the information for 

4 people or you cannot advance).

Resolved.

No Change.

The Department of Education limits the 

collection of information to data necessary to 

determine eligibility in order to simplify the 

application process. The verification selection 

process is separate from the application 

process and takes place after the FAFSA has 

been submitted.

7) It would be most helpful if the field for marital status for both 

student and parent were not pre-filled in renewal 

applications. This is because the marital status can and does 

change from year to year, and many of the verification issues 

we are seeing arise from the household information 

conflicting with the tax filing status. 

For instance, if the parent marital status has been divorced 

Resolved. For the 2014-2015 Renewal FAFSA, the parental 

marital status and dates are not being carried 

over. In addition, FAFSA on the Web will have 

new logic that compares the marital status with 

the response to the new tax filing status

question for both students and parents. In this 

situation, the applicant would be alerted that 

he or she may need to make additional updates 
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Comment Status Resolution 

previously, and then the IRS DRT is used showing tax filing 

status is married filing jointly due to the parent remarrying, 

then the FAFSA is most likely selected for verification. If the 

applicant was allowed to answer the marital status question 

each year, that might eliminate some of the FAFSA's that are 

currently being selected for verification.

to his or her application.

8) 1. Even though almost all (98%) FAFSAs are now expected to 

be filed online the draft 2014-15 FOTW is not available for 

public comment in either static or interactive form, nor has it 

been in previous years. For example, a preview of the 2013-

14 FOTW was not made available until late December 2012, 

too late to make any substantial improvements for the 

upcoming year. Making a preview version of the FOTW 

available during the public comment period would provide 

stakeholders the opportunity to weigh in on proposed 

changes and suggest improvements. Some information about 

FOTW is available in the “Data Elements and Justifications” 

chart and “Summary of Enhancements to the 2014-15 Free 

Application for Federal Student Aid (FAFSA),” but these 

textual descriptions of aspects of the online application are of 

limited use without an accompanying visual depiction of how 

applicants work their way through the process.

2. We appreciate that applicants going through the main 

FAFSA portal (http://www.fafsa.ed.gov) are not actively 

encouraged to fill out the FOTW Worksheet before using 

FOTW, because this static worksheet lacks the skip logic and

other helpful features of FOTW and may be confused with the 

paper FAFSA. However, to the extent that the Department 

continues to provide the FOTW Worksheet as a resource for 

students, it should also be available for public comment. 

Unlike previous years, the draft 2014-15 FOTW Worksheet is 

1. Resolved. 

No Change.

2. Resolved. 

No Change.

1. The updates that are included in each year’s 

application release take a considerable amount 

of input and effort by a large number of parties 

to define the requirements, ensure the 

accuracy of the functionality, develop the 

system, test the system and resolve any issues, 

apply security protocols, and clear the 

application with OMB. Because of the 

extensive amount of time needed to complete 

all of these activities, the date on which the 

application is currently provided via the FAFSA 

on the Web Demo site is the earliest that is 

possible. For 2014-2015, the Demo site is 

expected to be available on December 29, 

2013.

2. The Department of Education makes the 

FAFSA on the Web Worksheet available to 

students as a resource to assist them with 

completing the online application. This 

Worksheet does not ask for any additional data 

that is not already collected in the FAFSA and 

no burden to the public is associated with the 

Worksheet. Consequently, the FAFSA on the 

Web Worksheet is not part of this information 

collection Clearance. However, it will be 
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Comment Status Resolution 

not included in the attachments for this information 

collection request.

released through the Information for Financial 

Aid Professionals (ifap.ed.gov) website once it 

becomes available. 

9) We recommend that the Department move “What is the 

FAFSA?” (currently page 10) to page 2 (in place of the first 

page of the Notes section that is currently on page 2). This 

important contextual information should be at the beginning, 

not the end, of the paper FAFSA. Moving it to the front of the 

form would allow students to learn more about the FAFSA 

before they start filling it out.

To prevent confusion and make all the relevant information in 

the Notes section easier for applicants to see and use, we 

suggest moving the text currently on pages 2 and 9 to the end 

of the form, creating one continuous Notes section on pages 

9 through 10.

Resolved.

No Change

The Department of Education needs to further 

assess this recommendation and will consider 

this as a potential future enhancement to the 

paper FAFSA. 

10) Using Your Tax Return

This section of the paper FAFSA is an important opportunity 

to promote the simplified online application process and 

encourage electronic filing. We greatly appreciate the 

Department’s ongoing efforts to improve the IRS Data 

Retrieval Tool. However, more can be done to encourage the 

use of FOTW and the IRS Data Retrieval Tool both for initial 

application and for any necessary corrections.

We suggest changing the text of this section as follows:

If you (or your parents) need to file a 2013 income tax return 

with the Internal Revenue Service (IRS), we recommend that 

you complete it before filling out the FAFSA. If you have not 

Resolved. The text in the “Using Your Tax Return” section

has been revised.

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.
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Comment Status Resolution 

completed your return yet, you can submit your FAFSA now 

using estimated tax information, and then you must correct 

that information after you file your return.

The easiest way to complete or correct your FAFSA with 

accurate tax information is by filing online and using the IRS 

Data Retrieval Tool through www.fafsa.gov. In a few simple 

steps, most students and parents who filed 2013 tax returns

can view and transfer their tax information directly into the 

online FAFSA at www.fafsa.gov. you may be able to view your 

tax return information and transfer it directly into your 

FAFSA.

11) Filling Out the FAFSA

Especially in difficult economic times, it is critical that 

students and families know to inform financial aid offices

when their tax return does not reflect their current financial 

situation. To help applicants understand what kinds of 

“unusual circumstances” are relevant and how to address 

them, we recommend rewording the phrase that begins with 

“If you or your family has unusual circumstances...,” to:

If you or your family has unusual circumstances that might 

affect your financial situation experienced significant changes 

to your financial situation since filing your 2013 taxes (such as 

loss of employment), complete this form to the extent you 

can, then. Then submit it as instructed and consult with the 

financial aid office at the college(s) you applied to or plan to 

attend.

Resolved. The first paragraph in the “Filling Out the 

FAFSA” section has been revised.

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.

12) Step Two (Student) and Step Four (Parent) (Pages 4 and 6)

The Department proposes adding two new questions about 

Forwarded 

to 

appropriate 

The Department of Education plans to issue 

guidance on this topic.
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Comment Status Resolution 

the student’s and parent’s tax filing status for 2013, to 

identify instances where the reported marital status on the 

FAFSA is inconsistent with the IRS tax return filing status. 

While we appreciate the need to address such conflicts, we 

request that the Department clarify the process for resolving 

inconsistencies in this information. Resolving such 

inconsistencies should not cause confusion or undue delays 

for students and families.

business 

unit. 

13) Step Three (Student) (Page 5)

Questions 56-58: Unaccompanied homeless youth

For several years, we have urged the Department to fix a 

persistent statutory problem in the FAFSA questions 

regarding homelessness, and to make it easier for students 

using the paper FAFSA to understand what they are being 

asked. As detailed below, we continue to recommend that 

instead of asking three separate questions that attempt to 

capture the various ways an applicant might qualify as an 

independent student due to being homeless or at risk of 

homelessness, the form should ask just one simple question 

accompanied by a more detailed Notes section.

Title 20 of the U.S. Code specifies that certain unaccompanied 

youth meet the definition of independent students if they are 

homeless or are self-supporting and at risk of homelessness, 

and if they receive an official determination of their status 

from one of four sources. However, the draft language for 

questions 56 and 57 does not currently include those 

unaccompanied youth who are determined to be selfsupporting and at risk of homelessness, as mandated by 20 

U.S.C. 1087vv (d)(1)(H). The statutory language follows, with 

Resolved. Questions 56 - 58 will remain separate on the 

FAFSA. However, Questions 56 and 57 will be 

reworded to add “or were self-supporting and 

at risk of being homeless” to the end of each 

question. This change is consistent with the 

language that is in the law.

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.
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Comment Status Resolution 

italics for emphasis:

(H) has been verified during the school year in which the 

application is submitted as either an unaccompanied youth 

who is a homeless child or youth (as such terms are defined in 

section 725 of the McKinney-Vento Homeless Assistance Act), 

or as unaccompanied, at risk of homelessness, and selfsupporting, by—(i) a local educational agency homeless 

liaison, designated pursuant to section 722(g)(1)(J)(ii) of the 

McKinney-Vento Homeless Assistance Act; (ii) the director of 

a program funded under the Runaway and Homeless Youth 

Act or a designee of the director; (iii) the director of a 

program funded under subtitle B of title IV of the McKinneyVento Homeless Assistance Act (relating to emergency shelter 

grants) or a designee of the director; or (iv) a financial aid 

administrator; or;

We recommend replacing questions 56, 57, and 58 – which 

are long, confusing, and still do not cover all of the potential 

combinations of status and source of determination – with 

the following single question, which is already used as a 

filtering question in FOTW:

On or after July 1, ____ [relevant year], were you homeless or 

at risk of being homeless? (See Notes on p.__ for how to 

answer this question.)

The new question would be accompanied by a reference to 

the Notes section, and the first paragraph of the Notes for 

this question would read:

Answer “Yes” if you received a determination that you were 
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Comment Status Resolution 

an unaccompanied youth who was homeless, or selfsupporting and at risk of homelessness, from any of the 

following sources at any time on or after July 1, 2013:, that 

you were an unaccompanied youth who was homeless or, for 

question 58, at risk of being homeless.

- Your high school or school district homeless liaison

- The director, or designated staff, of an emergency shelter 

program funded by the U.S. Department of Housing and 

Urban Development

- The director, or designated staff, of a runaway or homeless 

youth center or transitional living program.

- A financial aid administrator at the school you attend or plan 

to attend.

14) Step Four (Parent) (Page 6) Questions 59, 61-64, 65-68

We applaud the Department for recognizing households with 

two legal parents, regardless of their gender or marital status. 

To assist dependent students whose parents are “unmarried 

and both parents living together,” we recommend creating an 

online resource with information about how these students 

should fill out questions 80-94. The current instructions on 

page 6 and page 9 (Notes for Step Four, questions 59-94) 

refer students to 1-800-4FED-AID. Students unable to call 

during the operating hours for that hotline (Monday-Friday, 

8am-11:59pm ET) or with frequently asked questions would 

benefit from user-friendly online information, which could 

also reduce the need for phone assistance.

Forwarded 

to 

appropriate 

business 

unit.

The Department of Education has referred this 

suggestion to the appropriate business unit to 

review recommendations. 

15) Question 94a: Parents’ 2013 Untaxed Income

To avoid confusion with similar-sounding categories on the 

W-2 form, we recommend adding the following language to 

Resolved. The untaxed income questions (paper FAFSA 

Question 45a and 94a) will be updated to 

include the recommended text.

For more information, see the document 
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Comment Status Resolution 

this question:

a) Payments to tax-deferred pension and savings plans (paid 

directly or withheld from earnings), including, but not limited 

to, amounts reported on the W-2 forms in Boxes 12a through 

12d, codes D, E, F, G, H and S. Don’t include amounts 

reported in code DD (employer contributions toward 

employee health benefits).

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.

16) Notes for questions 16 and 17

We recommend replacing the unnecessarily detailed and 

potentially intimidating reference to the Defense of Marriage 

Act with a shorter instruction about how to report marital 

status.

Report your marital status as of the date you sign your FAFSA. 

If your marital status changes after you sign your FAFSA, 

check with the financial aid office at the college. Because 

same-sex unions are not recognized by federal law, only 

report opposite-sex marriages on the FAFSA. According to the 

Defense of Marriage Act (1996), “...the word ‘marriage’ 

means a legal union between one man and one woman as 

husband and wife, and the word ‘spouse’ refers to a person 

of the opposite sex who is a husband or a wife.” Therefore, 

same-sex unions are not considered marriages for federal 

purposes, including the FAFSA.

Resolved. As a result of the recent Supreme Court 

decision on the Defense of Marriage Act, the 

Department of Education believes this 

recommendation is no longer applicable. 

However, the Notes for questions 16 and 17 

have been revised to reflect new guidance. .

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.

17) Notes for question 18 (State of legal residence)

We recommend providing some guidance about what “state 

of legal residence” means in the Notes section. For example, 

how should dependent students respond if they attend

college in one state but their parents live in another state?

Resolved. 

No Change. 

The response to Question 18 varies by state. 

Section 483(a)(1) of the Higher Education Act, 

as amended, requires inclusion of data items 

selected in consultation with the states to assist 

the states in awarding state student financial 

assistance. 
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Comment Status Resolution 

18) Notes for questions 56-58

To simplify the application process for homeless youth and 

maintain consistency with legislative intent, we continue to 

recommend revising the Notes as follows:

• “Youth” means you are 21 23 years of age or younger as of 

the day you sign this application.

The 21-or-younger definition of “Youth” in the draft Notes for 

questions 56-58 appears to conflict with legislative intent. 

While the statutory language of Title 20 does not specify ages 

pertaining to “unaccompanied homeless youth,” the 

congressional record shows clear intent to provide federal 

student aid access to unaccompanied homeless youth who 

would not otherwise qualify as “independent” and are unable 

to provide parental information. Additionally, the 

Government Accountability Office, in advising Congress on 

this and related issues, has defined disconnected youth as 

“youth aged 14 to 24 who are not in school and not working, 

or who lack family or other support networks.” Defining 

homeless youth aged 22 and 23 as independent, just like 

homeless youth aged 21 and younger, would address an 

unintended, unfair, and unnecessary disparity in the 

treatment of these vulnerable young people, simplifying their 

application process and ensuring they receive the aid they are 

eligible for.

If our proposed change is not accepted, we request 

clarification on the “alternate path” for homeless youth aged 

22 and 23. The “Data Elements and Justification” document in 

Additional 

Research 

Needed.

The Policy team at the Department of 

Education is researching this issue. For now, 

the change recommended in this comment will 

not be made for the 2014-2015 FAFSA.

The alternate path in FAFSA on the Web for any 

applicant whose age is 22 or 23, and does not 

answer “yes” to any of the FAFSA dependency 

questions:

The applicant answers “yes” to “On or after July 

1, 2013, were you homeless or were you at risk 

of being homeless?” The applicant then clicks 

on the “Next” button, and is taken to the 

“Homeless Circumstances” page.

The applicant reviews the information on this 

page and selects one of the following:

I will provide parental information, OR

I am homeless or at risk of becoming homeless

If the applicant selects “I am homeless or at risk 

of becoming homeless” and then clicks “Next” 

to continue, he or she is taken to the “Unable 

to Provide Parental Information” page.

The applicant reviews the information on this

page and selects one of the following:

I will provide parental information; OR

I am unable to provide parental information 
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Comment Status Resolution 

this information collection states:

Students aged 22 or 23 who answer “Yes” to the Homeless 

Filtering question will be taken down an alternate path to 

allow them to submit their application without parental data 

and follow-up with the financial aid office.

This “alternate path” is not explained in these materials and it 

is not clear what the consequences are for these students if 

they do not provide parental information while still being 

considered dependent. Generally, dependent students who 

do not provide parental information are not eligible for Pell 

Grants or subsidized Stafford loans, and can only receive 

unsubsidized Stafford loans at the discretion of the college’s 

financial aid office.7 Homeless youth aged 22 and 23 should 

have access to the same federal aid options as homeless 

youth aged 21 and younger.

and acknowledge that my FAFSA will be 

submitted without calculating an EFC

If the applicant selects “I am unable to provide 

parental information and acknowledge that my 

FAFSA will be submitted without calculating an 

EFC” and then clicks “Next” to continue, he or 

she is taken to the “Student Finances 1” page to 

begin entering his or her own financial 

information, bypassing the pages that collect 

information about the parent(s). Upon 

submission of the FAFSA, no EFC is calculated, 

and the “Special Circumstances” flag on the ISIR 

is set to “3” (Unaccompanied homeless 

individual). This alerts the FAA to the reason 

why no EFC was calculated, and helps the FAA 

to determine what additional information to 

request from the applicant to make the final 

determination on the applicant’s homeless 

status. 

If the FAA approves the applicant’s homeless 

status, the FAA indicates this by setting the 

“Dependency Override” flag to “4” (Homeless 

youth determination). The system then treats 

the student as independent and calculates an 

EFC.

The specific text that is presented to students 

who follow this path can be viewed in the 

demonstration version of FAFSA on the Web, 

available at fafsademo.test.ed.gov. 
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Comment Status Resolution 

19) What is the FAFSA? (Page 10)

We recommend adding the following language in italics to the 

last sentence of the “How do I find out what my Expected 

Family Contribution (EFC) is?” section for clarification:

You can make corrections or provide additional information, 

as necessary, online at www.fafsa.gov (using your PIN) or by 

following the instructions on page 5 of your SAR.

Space constraints understandably limit the amount of 

information on the paper form, but applicants would benefit 

from knowing a little more about what to expect after 

submitting the FAFSA. It would be helpful for this section to 

briefly explain the next steps in the aid process: after filling 

out the FAFSA, students will receive a Student Aid Report 

(SAR), which summarizes the data they submitted on the 

FAFSA and provides information on federal aid eligibility. 

Later, they will receive financial aid award letters from 

colleges where they apply and are accepted with more details 

about all the aid they qualify for. The Department has already 

recognized the need for such information by answering the 

question, “Who will I hear from, and when?” at 

http://studentaid.ed.gov/fafsa/next-steps#who-will-i-hearfrom-and-when.

Resolved. 

No Change 

The Department of Education believes the

current output documents provide adequate 

guidance.

20) 1. On the first page of the 2013-14 FOTW Worksheet, the text 

in the “Applying is easier with the IRS Data Retrieval Tool!” 

box reads: “Beginning in early February 2013, students and 

parents who have completed their 2012 IRS tax return may 

be able to use FAFSA on the Web to electronically view their 

tax information. With just a few simple steps, the tax 

information can also be securely transferred into the FAFSA.” 

1. Resolved

2. Resolved.

3. Resolved. 

No Change.

1 and 2. The paper FAFSA and the FAFSA on the 

Web worksheet contain updated instructional 

text in this section. 

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 
As of 10/22/2013 7:44 PM Page | 14

Comment Status Resolution 

To improve clarity, we suggest rewording this text in the 

2014-15 FOTW Worksheet to:

Beginning in early February 2014, students and parents who 

have filed their 2013 IRS tax returns will be able to securely 

view and transfer their own tax information right into the 

online FAFSA with just a few simple steps.”

2. See our suggestion above for improving the wording of 

“Using Your Tax Return” on page 1 of the paper FAFSA, to 

better encourage the use of the IRS Data Retrieval Tool.

3. We strongly encourage the Department to mark the 

questions on the FOTW Worksheet, and on the paper FAFSA, 

that could be pre-populated using the online IRS Data 

Retrieval Tool. The 2013-14 FOTW Worksheet currently asks 

users to fill in several pieces of data from their tax forms that 

could be pre-populated instead, but this is not made clear to 

the user.

4. While we commend the Department for mentioning the 

IRS Data Retrieval Tool in a box on page 3 of the 2013-14 

FOTW Worksheet labeled “Did you know?” and describing it 

as “the easiest way to provide accurate tax information,” this 

text is too easy to miss compared to more prominent and 

repeated exhortations to have tax returns in hand. The bold 

text at the bottom of the box to the immediate right titled 

“Did your parents file or will they file a 2012 tax return?” 

says, “Your parents will need their tax returns and/or W-2 

forms to complete the FAFSA.” This appears to contradict the 

adjacent message encouraging use of IRS Data Transfer. 

There is a similar problem with the boxes at the top of page 4 

4. Resolved. Aid.

3. No change.

4. The text “You/Your parents will need...” has 

been removed from the FOTW Worksheet and 

similar text has also been removed from the 

Paper FAFSA.
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Comment Status Resolution 

of the 2013-14 FOTW Worksheet. We recommend merging 

the adjacent boxes in these sections and using the expanded 

space to help applicants understand how the IRS Data 

Retrieval Tool can make the FAFSA easier to complete, and 

when they can expect their tax information to be available for 

transfer.

21) 1. We strongly urge the Department to work with the IRS to 

extend the substantial benefits of IRS data retrieval to more 

applicants and potential applicants. In its current form, the 

IRS Data Retrieval Tool only draws data from IRS 1040 forms, 

not from the W-2 or 1099 forms that can provide important 

earnings information for those who do not file a 1040 

because they earn too little to owe federal income tax. 

Almost three-quarters of Pell Grant recipients have incomes 

so low that they do not owe federal income tax, as discussed 

in more detail in our 2010 report, After the FAFSA: How Red 

Tape Can Prevent Eligible Students from Receiving Financial 

Aid.

2. We encourage the Department to consider how the IRS 

Data Retrieval Tool could be integrated into the 

FAFSA4caster. This would not only help provide early aid 

eligibility estimates to students and parents just beginning to 

explore college options and affordability, but also make them 

aware of the Tool well before they face the FASFA itself.

1. Resolved. 

No Change.

2. Resolved. 

No Change.

1. The IRS Data Retrieval Tool does not include 

W-2 information as a separate line item, and to 

obtain this information would be a 

collaborative effort between the IRS and the 

Department of Education. The Department will 

have conversations to explore this issue. In 

the meantime, the Department will continue to 

reach out to low income and non-tax-filers to 

communicate helpful information about the 

benefits of filing a tax return, including 

information about our partnership with the 

Volunteer Income Tax Assistance (VITA) 

Program, which provides tax return preparation 

assistance to low-income tax payers. 

2. FAFSA4caster does not collect personally 

identifiable information. In order to use the IRS 

Data Retrieval Tool with FAFSA4caster, 

personally identifiable information would need 

to be entered. FAFSA4caster is intended to be 

a quick estimate of the financial situation of the 

applicant.

22) Page 1 [Student Aid Report] (SAR)

1. We encourage the Department to place and present 

information on the SAR so that it is most helpful for students 

1. Resolved. 

No Change.

2. Resolved. 

1. The current design of the Student Aid Report 

(SAR) is based on previous usability studies that 

were conducted with applicants. The 

Department of Education believes the layout of 
As of 10/22/2013 7:44 PM Page | 16

Comment Status Resolution 

and their families. The first page should include a table of 

contents or outline that tells applicants what they will find in 

the different sections of the SAR.

2. Also on this page, applicants should be notified of the 

portability of federal student aid. Applicants need to know 

that federal aid can be used to cover higher education 

expenses including tuition and fees, living expenses (room 

and board), books and supplies, and transportation and 

miscellaneous personal expenses. This important information 

will help students and their families as they apply for college 

and review financial aid award letters, since it is a common 

misperception that financial aid is only for tuition and fees.

3. The Department should also consider incorporating data on 

the selected colleges’ net price by income, or at least links to 

the colleges’ net price calculators, into the SAR. This would 

give applicants important, school-specific information about 

the costs they may be expected to cover based on their 

families’ circumstances.

No Change.

3. Resolved. 

No Change.

the SAR is sufficient to inform applicants about 

what they need to know, and considers that a 

table of contents or an outline is unnecessary

and would cause undue burden on the public.

2. The Department of Education has published 

several resources geared towards students to 

help them understand federal student aid. 

These resources can be found on

StudentAid.gov

3. This information is covered adequately in 

other places, such as StudentAid.gov, the 

school award letters and the Shopping Sheet at 

ED.gov.

23) Page 2 [Student Aid Report] (SAR)

We recommend moving the Office of Management and 

Budget’s (OMB) legal disclosure and a section reserved 

exclusively for Financial Aid Office use from page 2 to the end 

of the SAR packet. In the online SAR, the OMB legal disclosure 

already appears at the end.

Resolved. 

No Change.

Shifting the legal disclosures from page 2 to 

page 11 on the paper Student Aid Report (SAR) 

would place the disclosure on the back of page 

10. Since page 10 needs to be submitted in the 

event a correction is made to the paper SAR, 

this would mean that the disclosure would also 

be submitted. The Department of Education 

prefers that the student retain the disclosure 

with their records.

24) Page 3 [Student Aid Report] (SAR)

1. The “What You Must Do Now” section should start with 

1. Resolved. 

No Change.

1. The “WHAT YOU MUST DO NOW...” section is 

customized to each applicant’s situation: the 

sample draft SAR is just that - a sample. The 
As of 10/22/2013 7:44 PM Page | 17

Comment Status Resolution 

the most immediate action, which is reviewing the 

information and making any changes necessary, including 

sub-bullets flagging where a correction or information is 

clearly required. It should also make explain, in the simplest 

terms possible, why these actions must be taken quickly. For 

example, the item currently at the top of this list in the 

sample draft SAR notes that NSLDS shows discharged loans, 

but it conveys neither urgency nor rationale. This should 

either appear lower on the list with improved wording or be 

moved to the “Summary of Federal Student Loans” section.

2. In addition, “What You Must Do Now” is be a more 

appropriate place to remind applicants to update their drug 

conviction status, if necessary, than the unnecessarily harshly 

worded “Warning” currently beneath the OMB disclosure on 

page 2.

2. Resolved. 

No Change.

information listed for each student conveys 

messaging and instructions specific to the 

individual. The Department of Education

believes the guidance, as laid out in this 

section, is adequate. 

2. The “Warning” text displayed on page 2 is a 

type of disclaimer displayed on all Student Aid 

Reports (SAR). In the event that a student has 

been convicted of drug distribution or 

possession with ineligibility for Title IV aid 

included as part of sentencing, there would be 

a match with the Department of Justice file, 

and specific SAR comments would appear on 

page 3.

25) Page 4 – Summary of Federal Student Loans [Student Aid 

Report] (SAR)

To help applicants better understand their current borrowing 

and repayment options for federal student loans, we 

recommend the following changes.

1. Rename subsection title to “Summary of Your Current 

Federal Student Loans.”

2. Include some reference to the term “Stafford,” as it may 

appear in financial aid award letters, is sometimes used in the 

Department’s consumer materials, and is frequently used in 

the interest-rate policy debate.

3. Delete the third paragraph under “Summary of Federal 

1. Resolved. 

No Change.

2. Resolved. 

No Change.

3. Resolved. 

No Change.

1. The information provided reflects data that is 

available from NSLDS at the time an initial 

application is processed; it may not necessarily 

be “current”.

2. The Department of Education uses the 

generic terms “Subsidized” and “Unsubsidized” 

on this page, and believes these terms are more 

descriptive and adequately convey loan type 

information.

3. The information provided is generic 

information; each student’s situation is 

different.
As of 10/22/2013 7:44 PM Page | 18

Comment Status Resolution 

Student Loans.” Instead of providing generic, hypothetical 

information about interest rates and monthly payments, it 

would be much more helpful to list the actual interest rates 

for each of the applicant’s outstanding loans under “Total 

Amount of Loans Outstanding.” Consider also providing the 

10-year payment for each outstanding loan and a total 10-

year payment based on totaloutstanding debt, if 

accompanied by basic information about other repayment 

plans and a link to a repayment calculator as described under 

2.c. below.

26) 1. Change “Total Amount of Loans Outstanding” to “Total 

Amount of Federal Loans Outstanding” and distinguish Direct 

Loans from FFEL Loans, listing Direct Loans first. Instead of 

referring to FFEL as “Bank Loans,” which could easily be 

confused with private loans, add an asterisk (*) after FFEL and 

provide a basic description that these are federal loans that 

were made through banks or other lenders before July 2010.

2. Add a new subsection, “More Information About Student 

Loans” that provides the following information:

a. The types of federal loans for which applicants may be 

eligible and the basic terms of these loans, as well as 

maximum annual loan amounts and the fact that they can 

borrow less than the maximum.

b. The possibility that the aid packages applicants later 

receive from schools will reference other types of loans as 

well, highlighting the terms and borrower protections unique 

to federal student loans and warning students and families 

about the risks of private student loans. This will help 

reinforce the Department’s important message in its online 

1. Resolved. 

No Change.

2. Resolved. 

No Change.

1. The Department of Education believes the 

text located above the chart provides adequate 

information about the “Summary of Federal 

Student Loans” section.

2. The Department of Education believes the 

information provided in this section of the SAR

is adequate. The purpose of the SAR is to 

provide information about a processed FAFSA. 

Links to the Web that contain important 

information such as the information suggested 

are made available on the paper SAR. 

However, to include the totality of this 

information on the paper SAR is impractical and 

will add undue burden to the public.
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Comment Status Resolution 

consumer information about borrowing – that federal loans 

should come first for those who need to borrow. See, for 

example: http://studentaid.ed.gov/types/loans/federal-vsprivate and http://www.ed.gov/blog/2012/10/five-things-toknow-about-your-student-loans/. Providing this essential 

information early in the aid process will help equip applicants 

to better evaluate whether, how, and how much to borrow.

c. Either in this section or immediately below “Total Amount 

of Federal Loans Outstanding,” the availability of different 

types of federal loan repayment plans, including incomedriven plans. This should be accompanied by a link to a single 

web-based calculator that estimates monthly payments 

under different repayment plans. If a multi-plan repayment 

calculator is not available by the time the 2014-15 SAR is 

finalized, then provide a link to the FSA “Repayment Plans” 

page, which has links to various plan-specific calculators, at 

http://studentaid.ed.gov/repay-loans/understand/plans.

27) Check Your SAR (Pages 5-10)

We suggest eliminating the fourth bullet point, “Use your 

Federal Student Aid PIN to make corrections online at 

www.fafsa.gov or send in pages 5-10 of this form,” and 

creating a new set of instructions for the header on page 5. 

We recommend that the Department use a slightly revised 

version of the instructions provided on page 3 of the draft 

SAR:

If you need to make corrections to your information, you may 

either make them online at www.fafsa.gov, or by using this 

SAR and mailing pages 5-10 to the address provided on page 

10. You must use your Federal Student Aid PIN to access your 

Resolved. 

No Change. 

The Department of Education believes the 

information provided in this section of the SAR

is adequate.
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Comment Status Resolution 

record online. If you need additional help with your SAR, 

contact your school's financial aid office or visit 

www.fafsa.gov and click the "Help" icon on the FAFSA home 

page. If your mailing address or e-mail address changes, you 

can make the correction online or send in the correction on 

your SAR.

28) There are two versions of page 10 in these draft materials, 

page 10Q and page 10V, but it is not clear why two different 

templates are necessary. To help applicants understand that 

they only need to read and sign the certification if they made 

changes to their SAR, we recommend modifying the draft 

page 10V as follows:

1. Move “If you made no changes” and the bullet point below 

that header to the top of the Certification section, above 

“Please read, sign, and date. You must read and sign this 

Certification.”

2. In the bullet under “If you made no changes,” specify the 

location of the SAR instructions that indicate whether the 

applicant needs to contact his or her school.

3. Move the Certification below the “If you made changes” 

section, and make the words “If you made changes” more 

visually prominent, especially “made changes.”

Resolved. 

No Change. 

The applicant will only receive one version of 

page 10 of the Student Aid Report (SAR). The 

version an applicant receives depends on 

whether or not the FAFSA has been rejected. 

Applicants with a rejected FAFSA receive page 

10Q of the SAR; this version contains the full 

certification statement for applicants to sign 

and submit. Applicants with a processed (nonrejected) FAFSA receive page 10V, which does 

not contain the full certification statement. 

29) The Department shouldprovide applicants with contact 

information for the financial aid offices of the schools they 

selected to receive FAFSA results. Contact information for 

colleges’ financial aid offices is not available via the College 

Navigator web site, so listing a phone number on the SAR 

would be a great help to applicants who need to speak with a 

financial aid representative.

Resolved. 

No Change. 

The suggestion in this comment cannot be 

implemented since different schools have 

preferred methods of how they wish for 

students to contact them.
As of 10/22/2013 7:44 PM Page | 21

Comment Status Resolution 

30) We also recommend moving the statement about where to 

find more information on the colleges listed on the FAFSA 

from the middle of page 10 to the first page of the SAR, so 

that applicants are more likely to see it. We further suggest

revised language to highlight the fact that more important 

consumer information is available on College Navigator than 

the online SAR:

For more information about the colleges you listed on your 

FAFSA, visit College Navigator at 

www.nces.ed.gov/collegenavigator or view your Student Aid 

Report online at www.fafsa.gov for the graduation, retention, 

and transfer rates. For the graduation, retention, and transfer 

rates of the colleges you listed on your FAFSA, view your 

Student Aid Report online at www.fafsa.gov. You can also find 

these rates and other important consumer information about 

the colleges you’re interested in on College Navigator at 

www.nces.ed.gov/collegenavigator.

Resolved. The Department of Education believes the 

statement provided in this section of the SAR is 

in a convenient location. However, text on 

Pages 10V and 10Q above Step Seven has been

updated to read: For the graduation, retention, 

and transfer rates of the colleges you listed on 

your FAFSA, view your Student Aid Report 

online at www.fafsa.gov. You can also find 

these rates and other important consumer 

information about the colleges you’re 

interested in attending at 

www.nces.ed.gov/collegenavigator.

31) My FAFSA Page

It is helpful that this page includes information about what 

happens next in the aid application process (see screenshot in 

Appendix A). We suggest adding the following to the fourth 

bullet point:

• The school(s) where you are accepted will send you a 

financial aid award letter with more details about all the aid 

you qualify for. If you have questions about your financial aid 

package contact your school(s).

We also recommend making the link to the SAR more 

prominent, to encourage applicants to review their processed 

Resolved.

No Change.

The design of the My FAFSA page and 

Confirmation page, including the SAR links, are 

based on recent usability studies and customer 

feedback.
As of 10/22/2013 7:44 PM Page | 22

Comment Status Resolution 

information to see if any additions or corrections are needed. 

On the “My FAFSA” page, the SAR is just one of three sets of 

small links at the bottom.

32) Electronic SAR

To clarify the purpose of presenting the processed FAFSA 

information in the SAR and the instructions for making 

corrections, we suggest modifying the text under “WHAT YOU 

MUST DO NOW” on both the PDF and HTML versions of the 

online SAR to say:

WHAT YOU MUST DO NOW (Use the checklist below to make 

sure that all of your issues are resolved.)

Review the information you submitted on the FAFSA (shown in 

the table below) to see if any additions or corrections may be 

needed. If you need to make corrections to your information, 

go to the FAFSA on the Web Corrections page. click 'Make 

FAFSA Corrections' on the 'My FAFSA' page. You must use 

your Federal Student Aid PIN to access your record online. If 

you need additional help with your SAR, contact your school's 

financial aid office or click the 'Help' icon on the FAFSA home 

page. If your mailing address or e‐mail address changes, you 

can make the correction online.

Since this document is presented online, the reference to the 

“FAFSA on the Web Corrections page” should be a clickable 

link, not a set of directions that requires the applicant to go 

back to the main “My FAFSA” page to find a link to the 

corrections page.

Resolved. 

No Change. 

The Department of Education believes the 

proposed solution would cause confusion and 

introduce potential security risks. 

33) We recommend moving the last three paragraphs under the 

table for “Your Financial Aid History Information” to the 

Resolved. 

No Change.

The Department of Education believes the 

information provided in this section of the SAR
As of 10/22/2013 7:44 PM Page | 23

Comment Status Resolution 

“Comments About Your Information” section at the top, 

before “FAFSA Data,” and making the recommended wording 

change below. These paragraphs are:

At this point, the school(s) listed on your application FAFSA 

have access to your information. The school(s) may put 

together or change an aid package based on your Expected 

Family Contribution and notify you.

The amount of aid you receive from a school will depend on 

the cost of attendance at that school, your enrollment status 

(full-time, three-quarter-time, half-time, or less than halftime), Congressional appropriations, and other factors. 

Review your financial aid notification from the school(s) or 

contact the Financial Aid Administrator at the school(s).

Note: Your school has the authority to request copies of 

certain financial documents to verify information you 

reported on your application.

is in a convenient location, and the 

recommended text changes are unnecessary 

since this information is covered adequately in 

other places.

34) We begin with a general concern that, while references to 

legal, adoptive, and biological parents are necessary, FAFSA 

instructions must ensure that students do not interpret those 

references to mean that stepparent (i.e. non-legal parent) 

information should not be reported under any circumstances.

We recommend the following revisions to Step Four of the 

paper FAFSA:

1. After the sentence that reads “Complete this step if you 

(the student) answered “No” to all questions in Step Three”, 

we recommend adding this sentence: IMPORTANT - Before 

completing Step Four, review the notes for questions 59-94 

1. Resolved. 

No Change

2. Resolved.

3. Resolved.

No Change

4. Resolved. 

1. All notes and information on the FAFSA are 

important. Making the suggested change would 

undermine the importance of the entirety of 

the application.

2. Step Four (Parent) instruction will be revised

to include the recommended text.

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.
As of 10/22/2013 7:44 PM Page | 24

Comment Status Resolution 

on page 9.

2. We recommend changing this sentence: Current wording: 

If your parents are not married to each other and live 

together, answer the questions about both of them.

Proposed wording: If your legal (biological or adoptive) 

parents are not married to each other and live together, 

answer the questions about both of them.

3. We recommend the following revisions to the FAFSA on the 

Web (FOTW): In the “Parent Demographics Information” 

section (questions 59-74), we recommend displaying detailed 

“Who is considered a parent?” information prominently in 

the “Help and Hints” box, rather than simply linking students 

to that information via the “parents’” hyperlink.

4. FOTW “Who is considered a parent?” information should 

be revised to reflect instructions for (legal) parents who are 

not married to each other and live together. We recommend 

the following wording: If your legal (biological or adoptive) 

parents are not married to each other and live together, 

provide information about both of them.

3. In order to provide all of the guidance for 

who is considered a parent, the suggested 

change has been provided in a separate 

window as a Help Topic on FAFSA on the Web. 

The Help Topic window provides more space 

than the Help and Hints text “box.” 

The “Help and Hints” in FAFSA on the Web is 

intended to be a type of “quick reference” for 

users. Those who need additional information 

are instructed to click on the “More>>>” link in 

the “Help and Hints” box to get additional 

information.

4. The Department of Education is updating the 

help topic “Who is considered a parent?” and 

providing the recommended guidance.

35) I would like to request addition clarification for question #28 -

"Will you have your first bachelor's degree before July 1, 

2014". This does not address those students who receive a 

master's degree without obtaining a bachelor's degree (nor 

do the instruction, help, or hints). 

FSA Handbook, Volume 1 Chapter 6, page 1 

http://www.ifap.ed.gov/fsahandbook/attachments/1213FSA

HbkVol1Ch6.pdf states: A student who has earned a 

Resolved. The recommended clarification will be added to 

FAFSA on the Web help text.
As of 10/22/2013 7:44 PM Page | 25

Comment Status Resolution 

baccalaureate degree or a first professional degree cannot 

receive a Pell grant.

A student who completes a master’s program has earned a 

degree beyond the baccalaureate level (in many instances a 

professional degree), making her ineligible for a Pell grant 

even if she does not have a bachelor’s degree and enrolls in 

an undergraduate program.

I would respectfully request this clarification be addressed on 

the FAFSA.

36) In the past, schools will receive comment codes on the 

student's ISIR if the student is male and has failed to answer 

the question "Have you registered with Selective Service?", 

which pops up after answering the gender question. The 

student has the option to answer "Yes, No, or Register me." If 

the student overlooks this question, additional steps must be 

taken by the institution at a later time to acquire 

confirmation from the student confirming that this process 

has been completed. This causes inconvenient delays to the 

student and the institution in the providing of timely financial 

aid eligiblity.

Would it be possible to make this question a "required 

answer" field that MUST be answered before allowing the 

student to proceed on to the next page of the application? It 

would seem that this would only require a small bit of 

programming logic added to the current process. This simple 

addition would alleviate a lot of work from the institutions, 

while making greater strides in ensuring that the male 

students are addessing their federal responsibility

Forwarded 

to 

appropriate 

business 

unit.

This suggestion has been referred to the 

appropriate business unit to review 

recommendations. 
As of 10/22/2013 7:44 PM Page | 26

Comment Status Resolution 

37) 1. Paper FAFSA, page 2 - Great explanation on what status 

defines an eligible noncitizen (and what does not define as an 

eligible noncitizen). 

However, the following statement, "If you have a Social 

Security Number but are not a citizen or an eligible 

noncitizen, you should still complete the FAFSA because you 

may be eligible for state or college aid." may confuse states 

that require a separate application and not a FAFSA. 

For example: 

In CA, students in this situation must submit a Dream 

application and an affidavit form to be eligible for state or 

college aid. Unless they now plan to use the FAFSA, which I 

am not aware of. 

2. ALSO - Paper FAFSA, page 6 - For parents who do not have 

an SSN and enter 000-00-0000 & select "will file" or "already 

filed" has been red flagged as an error before final submission 

online (parents without SSN's do file taxes). Students have to 

click "check for errors" twice to bypass, or are unsure how to 

correct this error and do not submit thinking parents are 

required to have an SSN. 

I recommend that "check for errors" not hold or red flag 

FAFSA on the web submission for this reason. This could 

result in earlier submissions and students/parents less afraid 

to report information on FAFSA.

1. Resolved. 

No Change.

2. Resolved. 

No Change.

1. The guidance given is provided as 

clarification that the FAFSA cannot be 

submitted without a Social Security Number 

(SSN). The word “may” is used as a qualifier 

here because it is up to each individual state or 

institution to determine what is required for 

these students to apply for state or college aid.

2. While the Department of Education 

understands the commenter’s concerns, there 

is a definite need for this edit. Parents without 

a Social Security Number (SSN) are allowed to 

file a federal tax return with the IRS using a 

Taxpayer Identification Number (TIN). This edit 

allows the user to confirm that the information 

provided (that taxes were filed without an SSN) 

is correct. The user must click the “Check for 

Errors” button just once to confirm this 

information. When the information is 

confirmed, the Reject J override flag is set on 

the ISIR. The purpose of this flag is to inform 

the Financial Aid Administrator (FAA) that taxes 

were filed without a Social Security Number. 

The FAA then has the discretion to request 

additional information from the student.

38) As part of the federal Affordable Care Act, employers must 

now report the amount they contributed toward their 

employees health benefits in box 12 on the W-2 form. The 

Resolved. Refer to comment #15 for resolution.
As of 10/22/2013 7:44 PM Page | 27

Comment Status Resolution 

amount is reported with a code of "DD". 

FAFSA Questions #45a and 94a, "Deferred pensions," 

instruction students and parents to report amounts in W-2 

box 12 with codes D, E, F, G, H and S. Some families have 

incorrectly reported the DD amount here because they are 

confused between the "D" and "DD". This causes their income 

to be overstated by the amount of the employers 

contribution towards healthcare.

I believe these two questions need to be revised with explicit 

instructions IN BOLD that the "DD" amount should not be 

included. Please refer to the attached for suggested language.

39) FAFSA: page 2, notes for Q #50

The instructions do not include a caveat about basic training 

for certain service members.

Answer “Yes” (you are a veteran) if you (1) have engaged in 

active duty (including basic training) in the U.S. Armed Forces 

or are a National Guard or Reserves enlistee who was called 

to active duty for other than state or training purposes, or 

were a cadet or midshipman at one of the service academies, 

and (2) were released under a condition other than 

dishonorable. Also answer “Yes” if you are not a veteran now 

but will be one by June 30, 2015.

Answer “No” (you are not a veteran) if you (1) have never 

engaged in active duty (including basic training) in the U.S. 

Armed Forces, (2) are currently an ROTC student or a cadet or 

midshipman at a service academy, (3) are a National Guard or 

Reserves enlistee activated only for state or training 

Resolved. The Notes for question 50 have been updated 

to include the recommended text.

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.
As of 10/22/2013 7:44 PM Page | 28

Comment Status Resolution 

purposes, or (4) were engaged in active duty in the U.S. 

Armed Forces but released under dishonorable conditions.

Also answer “No” if you are currently serving in the U.S. 

Armed Forces and will continue to serve through June 30, 

2015.

Rationale: See 2013-2014 FSA Handbook, p. AVG-22.

40) FAFSA: page 2, notes for Q #16 and #17

Remove DOMA information and refer students to page 9

Report your marital status as of the date you sign your FAFSA. 

If your marital status changes after you sign your FAFSA, 

check with the financial aid office at the college. See 

additional notes on page 9.

Rationale: GEN-13-12

Resolved. The Notes for questions 16 and 17 have been 

revised to reflect new guidance. However, the 

reference to page 9 has not been added 

because questions 16 and 17 pertain to the 

student’s marital status, whereas the 

information on page 9 that the Department of 

Education believes this comment refers to is 

specific to the parents.

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.

41) FAFSA: page #6, Q #59

Add note to reference DOMA information on page 9.

Married or remarried, see notes, page 9.

Rationale: GEN-13-12

Resolved. The Step 4 instructions direct the applicant to 

the Notes on page 9, which have been updated 

to include guidance stemming from the recent 

Supreme Court decision on the Defense of 

Marriage Act.

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid
As of 10/22/2013 7:44 PM Page | 29

Comment Status Resolution 

42) FAFSA: page 6, instructions for completing Q #80-94 AND 

Page 9 notes

It would be helpful, and reduce potential errors, for ED to 

create a worksheet for students/parents to complete to 

determine whose information must be provided on the 

FAFSA.

ED would develop the worksheet, similar to the drug 

conviction worksheet.

Rationale: GEN-13-12

Resolved. Page 6 instructions and page 9 Notes have been 

updated to provide appropriate guidance.

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.

43) FAFSA: page 9

Add a section about the definition of marriage; it can be 

referred to on multiple sections of the application. 

Definition of “Married”

Due to the recent Supreme Court decision regarding DOMA, 

this language will need to be revised accordingly. We still feel 

this section is needed for additional clarification.

Rationale: GEN-13-12; Supreme Court Decision June 26, 2013.

Resolved. The Notes for Step Four on page 9 have been 

updated to reflect new guidance.

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.

44) Student Aid Report: page #1, Application Status, 2nd check 

box

Your FAFSA has been selected for verification. Verification is a 

process where your school confirms the data you reported on 

your FAFSA. Your school has the authority to contact you for 

documentation that supports income and other information 

Resolved. 

No Change.

This SAR comment is intended to define 

verification, not to state the consequences of 

not following up since the verification process 

varies by school.
As of 10/22/2013 7:44 PM Page | 30

Comment Status Resolution 

that you reported on your FAFSA. Your federal financial aid 

may be delayed until the school receives your requested 

information.

Rationale: This language will help the student understand the 

consequence of not providing the school with additional 

documentation. 

45) Student Aid Report: page #1, Federal Student Aid Eligibility, 

paragraph 1

The data submitted on your FAFSA is was used to calculate 

your Expected Family Contribution (EFC), which is 0000.

Rationale: The EFC has already been calculated based on 

submitted data. Therefore, past tense is accurate.

Resolved. 

No Change.

The Department of Education considers this 

suggestion a stylistic preference.

46) Student Aid Report: page #1, Federal Student Aid Eligibility, 

paragraph 2, sentence 2

Rather, you should think of the EFC as is an index that 

colleges use to determine how much financial aid you would 

could receive if you were to attend their school.

Rationale: Less confusing and more succinct text.

Resolved. 

No Change.

The Department of Education considers this 

suggestion a stylistic preference.

47) Paper Student Aid Report: Federal Student Aid Eligibility

Based on your EFC it appears that you may be eligible for a 

Federal Pell Grant of up to $5785, provided you have not met 

or exceeded the lifetime limit established for the Federal Pell 

Grant program. This amount may be adjusted based on FAFSA 

data changes and your enrollment status. You may also be 

eligible for other grants, low-interest student loans, and 

Resolved. 

No Change. 

The Department of Education believes the 

addition of this text changes the meaning of the 

paragraph. The text, as is, uses the qualifiers of 

“may” and “up to” to inform the student of 

maximum aid eligibility based on the 

information provided. The Department of 

Education is communicating general eligibility 

information; the proposed text does not 

support that goal.
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Comment Status Resolution 

work-study opportunities.

Rationale: This language reinforces for students that the 

amount of Pell listed on this SAR can change if any 

subsequent changes to the FAFSA are made.

48) Student Aid Report: page #4, Summary of Federal Student 

Loans, paragraph 3

Why use 5% as the interest rate? Why not use 6.8% as it 

provides a better estimate to borrowers?

Change 5% rate to 6.8% and change the approximate 

payment as well

Rationale: 6.8% is a better estimate for the majority of 

students, and at worst-case, it estimates the repayment 

higher than the actual; the 5% could estimate it lower than 

the actual.

Resolved. 

No Change.

The interest rates in the Summary of Federal 

Student Loans are set by legislation and the 

information is provided by the National Student 

Loan Data System (NSLDS). The percentage 

used in this section of the SAR is only an 

example.

49) FAFSA: page #1, Applying by the Deadlines, paragraph 3

Revise as follows: Check with your high school or the financial 

aid office about sources of state and college aid and their 

applicable deadlines.

Rationale: Clarity.

Resolved. 

No Change.

The Department of Education considers this 

suggestion a stylistic preference.

50) FAFSA: Part One, page #3, Q #13, sentence 4

Your e-mail address will also be shared with your state and 

the colleges listed on your FAFSA to allow then to 

electronically communicate with you.

Rationale: Clarity.

Resolved. 

No Change.

The Department of Education believes the 

proposed change is redundant as the term “email” means “electronic mail”. 
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Comment Status Resolution 

51) FAFSA: page #3, Q #26

When you begin college in the 2014-2015 school year, what 

will be your high school completion status?

Rationale: Clarity. School year is not a defined term and may 

create confusion.

Resolved. 

No Change.

School year is defined by the school and may be 

different depending on the school. 

52) FAFSA: page #4, column 2, notes for Step Four

Revise the Notes for Page Four, questions 59-94 by adding 

the language: If your parents are not married to each other 

and live together, select “Unmarried and both parents are 

living together” and provide information about them 

regardless of marital status or gender. Contact 1-800-4FEDAID for assistance completing questions 80-94.

Rationale: This additional statement clarifies that regardless 

of the parents’ gender, both unmarried parents’ information 

needs to be reported based on DCL.

Resolved. The Notes for Step Four, questions 59-94 

(pages 6 and 7) have been revised. 

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.

53) 1. One is to request a bigger warning to students to NOT 

include their parents in the number in college. If their family 

size is greater than 3, they are rarely verified, yet they are 

often including parents and we find out later that they didn't 

read it well. It has such a dramatic impact on the EFC that 

they should have to list the same info. on the FAFSA as they 

do on verification worksheet for all they report as in college 

(which school, number of credits, etc.).

2. The other item is related to an applicant updating tax 

information on the FAFSA. There should be a special popup 

reminding them to correct the "will file" question to "did file" 

when they update their tax information. Even better would 

1. Resolved. 

2. Resolved.

No Change

3. Resolved 

No Change.

1. A new sentence reminding applicants to not 

include parents has been added to the “number 

in college” question in FAFSA on the Web.

2. The current functionality in FAFSA on the 

Web is such that, when a student or parent 

returns to FAFSA on the Web to correct or 

update their tax information, and the current 

tax filing status is “Will file”, an alert displays on 

the Student Finances 1 or Parent Finances 1 

page reminding the user to update their tax 

filing status if they have now filed a tax return.
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Comment Status Resolution 

be an automatic update on that field on the FAFSA when they 

update. So many miss that step and we spend a lot of time 

telling families to change that flag, when it should be

somewhat automatic when they update their tax info. 

3. Also, since the IRS process works successfully for so many, 

maybe more instructions to the ones that it doesn't work for 

could be added. For the late filers, amended returns, newly 

divorced, etc., it is not easy for them to understand what to 

do next.

3. The current functionality in FAFSA on the 

Web is such that, when a student or parent is 

ineligible to use the IRS Data Retrieval Tool, for

any one of the following reasons:

 Filed as “Married filing separately, or

 Married and filed as Head of Household, or

 Filed an amended tax return, or

 Filed a Puerto Rican or foreign tax return

The following message displays: “Based on 

your response, you are not eligible to transfer 

your information from the IRS into this FAFSA. 

Click Next to continue.”

The Department of Education believes that this 

message is clear and easy to understand.

54) Payments to tax-deferred pension and savings plans (Q. 45a, 

94a) – 2 comments: 

Our QA analysis confirms this field is likely the most 

commonly misreported item on the FAFSA and we believe it is 

because families do not understand the question. Many 

families do not consider their contributions to retirement 

plans as payments to “pension and savings plans”; therefore, 

they report “zero” on the FAFSA but we often verify a 

contribution as indicated on W-2 forms in Box 12a – 12d. We 

suggest changing the language to include the word 

“retirement” which will help families better understand the 

question. 

1. Suggested Text: “Payments to tax-deferred retirement, 

pension and savings plans (paid directly or withheld from 

1. Resolved. 

2. Resolved.

1. Questions 45a and 94a have been revised. 

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.

2. Refer to comment #15 for resolution.
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Comment Status Resolution 

earnings), including, but not limited to, amounts reported on 

the W-2 forms in Boxes 12a through 12d, codes D, E, F, G, H, 

and S.”

In 2013/14, many students/parents included amounts from

W-2 form, Box 12, code DD as untaxed income. Box 12 code 

DD reports the cost of employer-sponsored health coverage 

and was intended to be informational only per the IRS 

instructions. We had to remove this amount as untaxed 

income on a number of FAFSA applications since the families 

reported it incorrectly.

2. Suggested Text to be added to instructions: “Do not 

include amounts in Box 12, code DD.”

55) Net Worth of Investments, including Real Estate (Q. 42, 91): 

When a portion of the primary home is being rented, the 

FAFSA does not instruct the family to report that portion of 

their home as “other real estate.” We suggest adding 

language to the “notes” on the FAFSA, page 2 for parents and 

students to include the rental portion of their home in the net 

worth of investments.

Resolved. The Notes for questions 42 and 43 (page 4), 45j 

(page 5), and 91 and 92 (page 7) have been

revised. 

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.

56) Net Worth of Businesses and/or Investment Farms (Q. 43, 

92): We commonly find families incorrectly include the net 

worth of their family-owned business and/or family-owned 

farm on the FAFSA. The “notes” on the FAFSA, page 2 clarify 

when to include or exclude the business/farm; however, we 

suspect that families are not referring to the special 

instructions. The current question specifies “don’t include a 

family farm or family business with 100 or fewer full-time or 

full-time equivalent employees.” We suggest adding more 

Resolved. 

No Change. 

The Department of Education believes the 

current language provides adequate guidance 

to answer these questions. 
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Comment Status Resolution 

specific language to this question for parents and students to 

clarify the definition of “family-owned.”

Suggested Text: “As of today, what is the net worth of your 

parents’ (or students’/spouses’) current businesses and/or 

investment farms? Don’t include a farm or business that is 

more than 50% owned and controlled by the family, and has 

100 or fewer full-time or full-time equivalent employees. See 

Notes page 2.”

57) First Bachelor’s Degree before July, 1, 2014 (Q. 28): Many of 

our undergraduate continuing students mistakenly respond 

“yes” to this question. We suggest formatting this question 

similar to how the illegal drug conviction question (Q. 23) is 

formatted, whereby the “no” response displays before the 

“yes” response. Perhaps reversing the order of the responses 

will reduce the number of incorrect responses.

Resolved. 

No Change. 

The Department of Education considers this 

suggestion a stylistic preference.

58) Background: Beginning in January of 2014, many states will 

be transitioning to an alternative high school equivalency test 

and will no longer be utilizing the GED. Educational Testing 

Service (ETS), in partnership with the University of Iowa, has 

developed the High School Equivalency Test (HiSET). Missouri, 

Montana and New Hampshire will be using HiSET and will no 

longer be using the GED as a measure of high school 

equivalency. Tennessee will be administering both HiSET and 

GED in 2014, and New York will be using the Test of Assessing 

Secondary Completion (TASC), developed by CTB McGraw Hill 

as their high school equivalency assessment. The Higher 

Education Act language regarding eligibility for financial aid 

does not reference the GED.

It instead uses the term “recognized equivalent certificate.” 

Unfortunately the actual FAFSA application does make 

Resolved. The GED response for FAFSA Question 26 has 

been revised.

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.

 
As of 10/22/2013 7:44 PM Page | 36

Comment Status Resolution 

reference to GED in question #26 (see below). ETS would like 

to ensure that test takers in states that have adopted HiSET 

as an alternative and wish to apply for financial aid, using the 

FAFSA, will not be penalized and be allowed to complete the 

FAFSA form without any confusion.

Language from FAFSA Application

26. When you begin college in the 2013-2014 school year, 

what will be your high school completion status?

High school diploma. Answer question 27. General 

Educational Development (GED) certificate. Skip to question 

28.

Request: In question #26, the term “General Educational 

Development (GED) certificate” should be replaced with the 

following: “A state-recognized high school equivalency 

certificate.” This change is needed to reflect that different 

high school equivalency assessments will be offered in 

various states.

59) 1. It would be helpful if the Middle Initial was required for all 

students who submitting the FAFSA for the first time or those 

who are updating their FAFSA from a previous submission. 

We had several cases where a student had an SSA match due 

to the fact that the middle initial was missing from their name 

however, they were able to submit the FAFSA without fill out 

that filed. 

2. Also it would be helpful if there was a note on the FAFSA 

encouraging students and parents to double check the 

amounts pulled in from the Data Retrieval tool- specifically 

1. Resolved. 

No Change.

2. Resolved 

No Change.

3. Resolved. 

No Change.

4. Resolved 

No Change.

1. Guidance is given directing the applicant to 

use their legal name. Since not all applicants 

have a middle name, requiring this field would

prevent those applicants from submitting the 

FAFSA. 

2. Question numbers 44e and 44f (student) and 

94e and 94f (parent) on the paper FAFSA and 

on FAFSA on the Web (as well as within the IRS 

DRT) currently instruct applicants to “exclude 

rollovers”. The Department of Education 
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Comment Status Resolution 

the Untaxed portion of pension and IRA distributions since 

the data retrieval tool is pulling over Rollovers that do not 

have to be counted on the FAFSA. This is hurting student's 

EFC whose parents are switching jobs and only transferred 

their retirement funding and did not actually receive a 

distribution.

3. I also have been seeing a huge increase in rejected FAFSA 

forms due to missing asset information. There has to be a 

way to require parents to answer this question. Do you 

exceed "yes or no" only and if yes then an amount should be 

required before submitting since it is based on they day of. 

4. Also in addition to the new filing status classifications it 

would be helpful if parents could indicate that they were 

approved for an extension since that requires that we collect 

an additional form. For example one of the responses for 

question 82 could be "Will File- Approved for Extension". 

5. Finally, for the marital status I think it would be helpful to 

change "Single" to "Never Married" since we have had several 

cases of divorced or separated parents selecting the "Single" 

option.

5. Resolved 

believes this guidance is sufficient.

3. Students and parents are required to provide 

asset information when submitting an online 

FAFSA unless they meet one of the following 

criteria:

 Student is eligible for an automatic zero EFC 

and reported a state of legal residence that 

allows the student to skip asset questions

 Student meets the simplified needs test and 

reported a state of legal residence that 

allows the student to skip asset questions, or

 Independent student or parents of a 

dependent student answered “no” to the 

“Do your assets exceed...” filtering question.

If the student does not meet any of the above 

criteria, the student (and parents if the student 

is dependent) must report asset amounts in 

order to submit the application.

4. The Department of Education believes that 

this scenario applies to a small population of 

applicants and the recommended change 

would create confusion.

5. The response of “Single” has been reworded

to “Never married” for the parents’ marital 

status question.

60) 1. Page 1. Instructions for Using Your Tax Return updated to 

indicate "you must correct" estimated tax information.

It is unclear whether this is something Financial Aid 

1. Resolved. 

No Change. 

2. Resolved. 

1. Currently, the Department of Education

supports the FAFSA correction process by 

sending notices to students and parents 

reminding them to correct their estimated tax 
As of 10/22/2013 7:44 PM Page | 38

Comment Status Resolution 

Administrators will need to monitor or if the Department of 

Education will monitor this. It should state in the instructions 

to families that when they are estimating tax information, 

award amounts based on that estimated data are subject to 

change. In addition, when corrections are required, it is not 

necessarily intuitive to students to click on "Make Corrections 

to a Processed FAFSA." 

2. This link should be displayed more prominently when 

students log into FOTW. 

3. The IRS Data Retrieval instructions should also be updated 

to make it clear that the IRS is matching their data on their 

personal information including an exact address. 

4. The error messages for the IRS DRT are not clear when an 

address has been typed incorrectly.

No Change.

3. Resolved. 

No Change.

4. Resolved.

information once their taxes are filed. 

Monitoring corrections is the responsibility of 

the school. Students are encouraged to make 

corrections whenever necessary on a paper SAR

or on FAFSA on the Web. Schools should use 

their communication channels to do the same.

When a student or parent submits a FAFSA on 

the Web with estimated tax information, the 

confirmation page displays dynamic text 

instructing them to “...update the 

information...reported on the FAFSA to reflect 

the actual information from the 2013 tax 

return...” The message then encourages 

parents and students to use the IRS Data 

Retrieval Tool when they update the 

information, if they are eligible. Schools can 

then use their own award letters to 

communicate award amounts to the student

2. The Department of Education believes that 

the current layout and links displayed on FAFSA 

on the Web are appropriate. The current 

designs, including the links, are based on recent 

usability studies and customer feedback.

3. The Department of Education works closely 

with the IRS to determine guidance for 

matching the address for the applicant to be 

able to use the IRS DRT. 

4. The Department of Education has been 
As of 10/22/2013 7:44 PM Page | 39

Comment Status Resolution 

working collaboratively with the IRS to make 

changes to the IRS Data Retrieval Tool that

address these authentication errors. As of

August 2013, additional guidance now displays

to users who are unable to successfully 

authenticate with the IRS due to an address 

mismatch.

61) Page 3. Questions 24 & 25, parents highest level of schooling

This is the first question which indicates Parent 1 & Parent 2, 

yet this is a unique question because the parents indicated in 

this question could be different than the parents indicated in 

other questions. Instructions should be added to state: 

"Parents in these questions are defined as the student's 

biological or adoptive parents, not stepparents, guardians, or 

foster parents."

Resolved.

No Change.

Questions 24 & 25 collect information to assist 

states and schools in awarding student financial 

assistance. Instructions or definitions beyond 

the existing statement (“Some states and 

colleges offer aid based on the level of 

schooling your parents completed.”) were 

intentionally excluded from these questions 

since the definition of parent may vary by state.

62) Pages 4 & 6. Questions 34 & 82, filing status

Instructions should indicate where to find this information on 

a tax return.

Resolved. Questions 34 and 82 have been reworded for 

clarity.

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.

63) Page 6. Question 59, parents marital status

1. The wording for unmarried parents living together should 

be sure to indicate biological or adoptive parents. 

2. Also, it should be clear which same sex parents should 

mark this answer. 

3. If biological parents are divorced and living together, it 

1. Resolved.

2. Resolved.

3. Resolved.

1, 2 and 3. The Notes and guidance for 

Question 59 have been revised.

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.
As of 10/22/2013 7:44 PM Page | 40

Comment Status Resolution 

needs to be clear which option they choose.

64) Page 6 & 7. Questions 61 - 68, Question 88 & 89, parent data

Students should have the ability to indicate which parents 

they are answering these questions about which would help 

alleviate flip-flopping of parent data.

Resolved. 

No Change.

When entering data on the FAFSA, either on 

paper or on the Web, it does not matter if the 

student (or the parent) inadvertently flip-flops 

the information for the two parents. This 

would have no effect on the EFC calculation.

65) Page 9. Notes for Step Four, questions 59-94, who is 

considered a parent

It would help to include examples. Students, parents, and 

financial aid administrators are having to re-learn who will be 

considered a parent, and examples help clarify this.

Resolved. Due to the scope of the definition of who is 

considered a parent, the Department of 

Education is unable to provide examples on the 

paper FAFSA. However, further guidance and 

examples will be provided through other official 

means.

66) From reviewing the paper FAFSA, it is unclear what, if any, 

additional logic will be added to FOTW to help students 

navigate through the new method of collecting parental 

information. 

1. For example, if filing status is inconsistent with marital 

status, will an edit catch this?

2. Will there be a way to track that Parent 1 and Parent 2 are 

used consistently?

1. Resolved.

2. Resolved. 

1. FAFSA on the Web logic will compare the 

marital status and tax filing status. If a conflict 

occurs, an edit and a SAR comment will notify 

the applicant, and an ISIR comment will notify 

the Financial Aid Administrator.

2. Refer to comment #64 for resolution.

67) We appreciate the efforts of the Department of Education to 

address all family structures; however, we feel there is still 

ambiguity in the instructions provided to students and 

parents. The instructions for “unmarried and both parents 

living together,” direct families to contact 1-800-4FED-AID for 

assistance. Students or parents may be unwilling to go this 

extra step without first receiving guidance on what this 

answer means, and they might interpret this to mean a 

parent’s boyfriend/girlfriend who is not a biological or 

Resolved. The Notes and guidance for “unmarried and 

both parents living together” have been 

revised.

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.
As of 10/22/2013 7:44 PM Page | 41

Comment Status Resolution 

adoptive parent to the student. We recommend providing 

examples of parents who fit this scenario as well as examples 

of what situations do not fit this scenario.

68) 1. Regarding the Parent 1 and Parent 2 questions, with the 

capabilities of FAFSA on the Web, it could ease a lot of 

burden by asking students to identify the relationship of each 

parent for whom they are providing information. When 

marital status is divorced, FOTW asks the student to indicate 

if they are providing information for mother or father. This 

could be updated to have a dropdown for both parents 

indicating biological/adoptive/step and mother/father, based 

on the marital status selected. Also, some step-parents feel 

they should not be included on the FAFSA, and some students 

think they should answer about biological, divorced parents 

even if they are not living together. 

2. Please make sure it is clear that answers for Parent 1 and 

Parent 2 are for parents in the student’s household.

1. Resolved. 

No Change.

2. Resolved. 

1. The simplified FAFSA on the Web is a result 

of continuous feedback from the community

and in accordance with the rules in the current 

Higher Education Act (HEA).

2. The Department will provide further 

guidance and resources to assist in answering

the parent questions on the 2014-2015 FAFSA.

69) Now that the Supreme Court has issued a ruling on the 

Defense of Marriage Act (DOMA), the financial aid community 

will need to understand how this affects collection of 

information on the FAFSA, not just for parents, but for 

students who are the same gender and married.

Resolved. The Notes for questions 16 and 17 (page 3) and 

the Notes for Step Four, questions 59-94 (pages 

6 and 7) have been revised to reflect new 

guidance. 

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.

70) We applaud the Department of Education (ED) for 

acknowledging today’s changing family structures by 

collecting information on the FAFSA from legal parents who 

live together, regardless of marital status or gender. This is a 

Resolved. The Notes for questions 16 and 17 (page 3) and 

the Notes for Step Four, questions 59-94 (pages 

6 and 7) have been revised to reflect new 

guidance. 
As of 10/22/2013 7:44 PM Page | 42

Comment Status Resolution 

positive step for both the simplicity and integrity of the 

federal aid process; by more accurately capturing what 

families headed by two legal parents can pay, we continue to 

emphasize that the primary responsibility to pay for college 

rests first with the family. We assume that further changes 

will be required to the FAFSA as a result of the recent 

Supreme Court decision to overturn the Defense of Marriage 

Act (DOMA). If resulting modifications are made, and timing 

allows, we encourage you to seek public comment on those 

changes.

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.

71) We appreciate ED’s continued efforts to clarify and improve 

the FAFSA structure and language, however we believe that 

you would receive much more useful feedback from the 

community if you instituted a similar comment process with a 

similar timeframe for the FAFSA on the Web (FOTW).

The vast majority of applicants use FOTW rather than the 

paper FAFSA and there are more significant changes to FOTW 

from year to year as compared to the paper FAFSA due to 

technological changes to skip logic, edits, and other 

assumptions. It is perplexing that there is no formal 

mechanism for the aid community to offer suggestions and 

comments on FOTW.

Resolved. 

No Change.

Refer to comment #8 for resolution.

72) Generally, the FOTW demonstration site 

(www.fafsademo.ed.gov) for the upcoming cycle is not 

available until mid-December. This late timeframe makes it 

nearly impossible for the financial aid community to provide 

useful feedback in time for ED to make any necessary or 

desired changes prior to the January 1 start-up date. We ask

that you make it a priority to have the demonstration site 

available to the community for comment at or near the same 

time you are soliciting comments on the paper FAFSA.

Resolved. 

No Change.

Refer to comment #8 for resolution.
As of 10/22/2013 7:44 PM Page | 43

Comment Status Resolution 

73) Page 4. Question 28. 

Will you have your first bachelor’s or professional degree 

before July 1, 2014 2015? In which year and month did 

you/will you earn your first bachelor’s or professional degree?

1. Students who complete certain graduate programs that do

not require baccalaureate degrees often answer this question 

“No,” making them appear to be Pell-eligible.

2. Also, schools report that it is difficult for them to know in a 

timely manner when students earn their first bachelor’s 

degree during the award year at another institution. These 

students answer the FAFSA question correctly, yet often have 

their Pell Grant award revoked late into the award year once 

the receipt of the bachelor’s degree is discovered.

The answer to this re-worded Question 28 could be compared 

to responses to Question 29 and 30, and appropriate edits 

and/or comments could alert students and schools of possible 

conflicting information.

1. Resolved.

2. Resolved. 

No Change

1. Refer to comment #5 for resolution.

2. Edits currently alert the student when there 

is a conflict between Question 29 and Question 

48. With the wide variety of academic programs 

offered among institutions, the Department of 

Education does not believe additional editing is 

appropriate.

74) Page 5 &7. Questions 45a & 93a. 

Payments to tax-deferred retirement, pension, and savings 

plans (paid directly or withheld from earnings), including, but 

not limited to, amounts reported on the W-2 forms in Boxes 

12a through 12d, codes D, E, F, G, H and S. Do not include 

amounts in Box 12, code DD.

1. Financial aid administrators report that this question is 

prone to underreporting, most likely because many families 

do not consider their contributions to retirement plans as 

1. Resolved.

2. Resolved.

1. Refer to comment #54 for resolution.

2. Refer to comment #15 for resolution.
As of 10/22/2013 7:44 PM Page | 44

Comment Status Resolution 

payments to “pension and savings plans”. Adding the word 

“retirement” would clarify what is to be included.

2. In the 2013-14 application year, many students/parents 

incorrectly included amounts from W-2 form, Box 12, code 

DD as untaxed income. Box 12 code DD reports the cost of 

employer-sponsored health coverage and was intended to be 

informational only per the IRS instructions.

75) Page 6. Question 59. 

As of today, what is the marital status of your legal parents?

__Never Married

__Unmarried and both parents living together

__Married or Remarried

__Divorced or separated

__Widowed

In certain circumstances, both the first and second options 

are applicable – how would the student decide which to 

select?

Since legal parents are defined in the introductory text to this 

question as “biological and/or adoptive parents”, this 

question can be misinterpreted to mean that stepparent 

information is not required on the FAFSA. For example, John’s 

biological parents are divorced and remarried to other 

people. Since “legal parents” refers to biological parents, he 

could reasonably read this question as asking about the status 

of his two biological parents, leading him to answer “divorced 

or separated” instead of “married or remarried”. There is 

further instruction on page 9 related to divorced parents, but 

we suggest that some additional instruction be added to near 

Resolved. 

No Change.

The responses to this question were re-ordered 

to intentionally display the Never married 

option first. 

The Department believes that the existing

guidance for this question (“If your parent was 

never married or is remarried, divorced, 

separated or widowed, see Notes page 9 for

additional instructions.”) addresses this 

comment.

In addition, the Notes on page 9 have been 

revised.

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.
As of 10/22/2013 7:44 PM Page | 45

Comment Status Resolution 

the question itself, as the addition of the term “legal parent” 

and its definition is likely to create some confusion.

76) Page 6. Questions 80, 81, 82.

For 2013, have your parents completed their IRS income tax 

return or another tax return listed in question 81?

What income tax return did your parents file or will they file 

for 2013?

What is or will be your parents’ tax filing status for 2013?

None of these questions has appropriate response options in 

situations where two parents are included on the FAFSA, but 

their responses to these questions may differ. These 

situations are more likely to occur in light of changes on 

reporting of parental information on the FAFSA.

Resolved. Help text is being added to FAFSA on the Web 

to clarify exactly what parents and students 

should enter in this situation.

Additionally, text in the “Using Your Tax 

Return” section on page 1 of the paper FAFSA

has been revised.

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.

77) Page 9. Notes for Step Four, questions 59-94

Additional instructions about who is considered a parent on 

this form:

• If your parent was never married or is widowed, answer the 

questions about that parent....

• If your parents are not married to each other and live 

together, select “Unmarried and both parents are living 

together” and provide information about them. Contact 1-

800-4FED-AID for assistance completing questions 80-94.

For unmarried parents, the first and last bullets can 

sometimes be contradictory. It appears that the last bullet in 

Resolved. The Notes for Step Four, questions 59–94 

(pages 6 and 7) have been revised.

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.
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Comment Status Resolution 

the instructions was added as a result of the change in 

reporting of parental information on the FAFSA, but 

necessary modifications to the first bullet were overlooked.

78) Page 10. Notes for Questions 35 and 84

If you filed a 1040 and were not required to file a tax return 

other than to claim a refund of withheld tax, answer “Yes” to 

this question.

An individual who must file a return to claim a refund of 

withholdings might misinterpret this instruction. Adding 

“other than to claim a refund of withheld tax” after “return” 

would help clarify.

Resolved. 

No Change.

The Department of Education believes this 

recommendation would change the meaning of 

the instructions, as there are additional reasons 

why someone might file a 1040 even though

they are not required to file a tax return.

79) Page 11. Question 26 

When you begin college in the 2014-2015 school year, what 

will be your high school completion status?

The “homeschooled” option needs more explanation in the 

instructions. Regulations require either a secondary school 

completion credential for home school from the student’s 

state, or if the state has no such requirement, that the 

schooling occurred in a home school setting exempted from 

state compulsory attendance requirements.

Resolved. 

No Change.

The Department of Education believes that the 

guidance provided is sufficient.

80) Page 6. Step 4

If your parent was never married or is widowed, divorced, 

separated or remarried, see the Notes on page 9 for 

additional instructions.

For clarity, insert “or is” after “married,”.

Resolved. The Step Four text has been revised.

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.
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Comment Status Resolution 

81) The purpose of the FAFSA is not to specifically designate a 

“Mother” and a “Father” for each applicant but rather to 

learn essential background information about those 

responsible for the care, health, and welfare of the applicant 

in question. The gender of the applicant’s parents has no 

bearing on the information collected and in cases where an 

applicant has two mothers or two fathers, the use of 

gendered terms can cause unnecessary delay and potential 

denial of appropriate financial aid. Applicants with two 

mothers or fathers face the impossible choice of either 

arbitrarily designating one parent as “Mother” and one as 

“Father” or leaving one parent off of the form. In fact before 

the proposed changes, applicants with same-sex parents 

were instructed to treat their same-sex parents as divorced 

and to list only one parent on the form.

We approve of the Department’s proposed changes to amend 

the collection of parental information by adding the response 

“Unmarried and both parents living together” to the existing 

responses for the parents’ marital status question. We also 

approve of the change to use the term “parent” instead of 

“mother” or “father” where applicable.

Include explicit instructions for applicants with unmarried 

parents

We approve of the change to include the new “Unmarried 

and both parents living together” response where applicable 

and to provide guidance informing applicants and parents 

how to input IRS information if the parents filed separate tax 

returns. We urge the Department to amend the Federal 

Student Aid (FSA) Handbook, the instructions to the paper 

Resolved. The FAFSA will provide appropriate guidance on 

how applicants should respond to the parents’ 

marital status questions.

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.
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Comment Status Resolution 

FAFSA, and the questions on the FAFSA websiteto include 

explicit instructions indicating how applicants with same-sex 

parents are to fill out these forms. Applicants will have 

parents in a number of legal configurations: married (see 

section on the Defense of Marriage Act), in a legally 

recognized domestic partnership or civil union, or unmarried.

There must be clear instructions for applicants with parents in 

each of these circumstances to understand how to correctly 

fill out the form.

82) Include examples of parents who qualify as legal parents

The Department must also amend the FSA handbook and 

FAFSA website to answer the question “who is considered a 

parent?” to include the following information. A parent 

qualifies as a “legal parent” if he or she is considered such 

under the state law where the applicant and parents live. 

Every state has different laws about who is a legal parent; 

states with comprehensive relationships recognition, such as 

marriage, civil unions, or domestic partnerships may consider 

a child of such a relationship the legal child of both parents. It 

may be unclear to an applicant whether his or her parent 

qualifies as a “legal parent.” As such, we recommend that the 

Department include the following guide in the Handbook, the 

instructions to the form, and the website for applicants who 

may not know if their parent is a legal parent:

A legal parent is anyone who:

Is an adoptive parent; or Has a valid court order saying he or 

she is a parent.

Other people who may be a legal parent include:

Resolved. Once final guidance is available, it will be 

available through the resources listed.
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Comment Status Resolution 

• A biological parent, unless they are a sperm or egg donor or 

a surrogate under state law, or their rights were terminated 

by a court;

• Parents who were married to or in a civil union or 

registered domestic partnership with a legal parent at the 

time of birth if the applicant lives in a state that recognizes 

their relationship; or

• In some states, parents who have lived with the applicant 

and held themselves out as a parent, who were intended 

parents who conceived the applicant through assisted 

reproduction, or who qualify under other state laws that 

recognize them as parents.

83) Remove mention of the Defense of Marriage Act

Clearly, now that the Section Three of the Defense of 

Marriage Act has been declared unconstitutional by the 

Supreme Court, there should be no mention of its restrictions 

on applicants or their parents in the Handbook, the 

instructions, or the FOTW.

Remove gendered parent terms

Now that applicants with married same-sex parents will be 

able to enter their parents as “married,” as opposed to 

“unmarried and living together,” we encourage the 

Department to interrogate whether the gendered parent 

terms “mother” and “father” retain any relevance. Take for 

example, an applicant with two mothers. If this applicant 

lived in Tennessee, where same-sex couples cannot marry, 

Resolved. Text referencing the Defense of Marriage Act 

has been updated to reflect new guidance. 

Additionally, all “Father” and “Mother” 

question labels have been replaced with 

“Parent 1” and “Parent 2.” 

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.
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Comment Status Resolution 

she would chose the appropriate marital status of “unmarried 

and living together” and be directed to fill in the information 

for her two “parents.” If the same applicant lived in 

Massachusetts, which allows same-sex couples to marry, and 

her mothers were married, she would rightfully chose 

“married” as their marital status. She would then be directed 

to complete information on her “mother” and “father,” 

despite having two married mothers. These gendered terms 

will lead to the same confusion on the part of applicants and 

administrators that the current update is seeking to avoid. 

We strongly recommend that the paper application and the 

FOTW both reflect the certainty that applicants will be 

completing information on both of their married, same-sex 

parents by changing all instances of “mother,” “father,” 

“step-mother,” and “step-father” to “parent.”

84) The FAFSA form currently requires applicants to indicate their 

current marital status. An applicant’s response to this 

question dictates the information requested in 20 subsequent 

questions which may not be answered if the applicant does 

not qualify as “married” under the given definition. The 

purpose of the form is to assess the financial status of the 

applicant to determine eligibility for federal education 

funding, so the exclusion of legally recognized relationships 

from the marital status question will lead to confusion for 

applicants and inaccuracy in calculations. This confusion and 

inaccuracy can cause delays in the processing of the 

application and ultimately affect the applicant’s opportunity 

to receive the financial assistance for which he or she would 

otherwise qualify.

1. Remove mention of the Defense of Marriage Act

1. Resolved.

2. Resolved.

No Change.

1. Text referencing the Defense of Marriage Act 

has been updated to reflect new guidance. 

For more information, see the document 

entitled Summary of Enhancements to the 

2014-2015 Free Application for Federal Student 

Aid.

2. Under the statute, even with the ruling on 

Section Three of DOMA, individuals in civil 

unions and domestic partnerships are not 

considered married for purposes of the FAFSA; 

these individuals are considered single. These 

students and parents should continue to report 

their marital status as something other than 

married.
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Comment Status Resolution 

Clearly, now that the Section Three of the Defense of 

Marriage Act has been declared unconstitutional by the 

Supreme Court, there should be no mention of its restrictions 

on applicants in the Handbook, the instructions, or the FOTW.

2. Add “legally recognized civil unions or domestic 

partnerships” to the list of marital statuses.

We recommend that “legally recognized civil unions or 

domestic partnerships” be added to the marital status 

question (16). The language of the form should add options 

for individuals living in a legally recognized civil union or 

domestic partnership. Clarifications of these relationships 

could be added to the instructions if needed. By virtue of the 

nature of these relationships, the participants are financially 

intertwined. Despite the Supreme Court’s decision that 

Section Three of the Defense of Marriage Act is 

unconstitutional and the federal government, including the 

Department of Education should be permitted to recognize 

these valid marriages, 37 states have some restriction on the 

ability of same-sex partners to access marriage. Seven states 

offer same-sex couples comprehensive domestic partnerships 

or civil unions. Applicants in these relationships should be 

permitted to list their partners on the FAFSA form. This is 

even more important given the proposed change to allow 

applicants to list both of their parents, regardless of marital 

status, if living together. To neglect to extend the same 

consideration to applicants and their legally recognized 

spouses may lead to confusion for applicants.

We recommend adding “legally recognized civil unions or 

domestic partnerships” to Question 16. Appropriate 
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Comment Status Resolution 

amendments to subsequent questions should likewise be 

amended. For example “husband” and “wife” should be 

changed to “spouse” or “domestic partner or civil union.”

16. What is your marital status as of today? See Notes page 2.

• I am single.

• I am married/remarried.

• I am in a legally recognized civil union or domestic 

partnership.

• I am separated.

• I am divorced/widowed.

85) Amend information about the Selective Service registration 

requirement to provide clearer information for transgender 

applicants.

Many transgender applicants would be unable to complete 

the FAFSA in its proposed form without confusion regarding 

Questions 21 and 22. We recommend three simple 

amendments to the proposed form to clarify the application 

and to hopefully reduce or eliminate delays in processing 

time for applicants who believe they are exempt from the 

Selective Service requirement.

Recommended Changes

Please clarify Question 21 "are you male or female," by 

instructing applicants to answer according to the gender 

marker currently associated with their Social Security record. 

Some transgender applicants may not have a consistent 

gender marker throughout all government identification 

systems. In those cases, it would be helpful for the applicant 

to know which system is being matched against in order to 

Forwarded 

to 

appropriate 

business 

unit.

This comment has been forwarded to the 

appropriate business unit that reviews policy 

recommendations.
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Comment Status Resolution 

provide an accurate answer and avoid a matching error and 

subsequent delays in processing the application.

In Question 22, add an option to check "I am exempt" next to 

"Register me!". Transgender men who are listed as male 

according to social security are currently exempt from 

registering for the Selective Service. Unlike other men who 

are exempt from registration, however, they may be unaware 

of the requirements for documentation, and would not have 

received any notification from Selective Service in that regard 

unless they changed their gender marker with the Social 

Security Administration before turning 18.

Rather than burdening applicants to work with each 

individual institution of higher education to provide 

appropriate documentation of their exemption from Selective 

Service registration, the Department of Education should put 

all exempt FAFSA applicants on notice of the Selective Service 

requirement and of the availability of a Status Information 

Letter.

This could be easily achieved by offering an opportunity to 

identify as a person who believes they are exempt (by 

checking a box), and by readily providing brief information 

regarding the availability of Status Information Letters in the 

notes for Question 22. By doing so, individuals who might 

have to provide documentation regarding their status would 

be prompted to take quicker action to compile it. This would 

also prevent further delays in the financial aid process and 

would allow for a quicker turnaround time between a failed 

data match in the Central Processing System and an 

applicant’s satisfactory response to the verification request.
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Comment Status Resolution 

86) Allow for a broader range of circumstances under which 

parental financial information is not required.

The current policy surrounding students who are not required 

to provide parental information is overly restrictive, and 

leaves out applicants in vulnerable family circumstances. As it 

stands, students who are homeless or have documentation 

demonstrating they are at risk of homelessness are exempt 

from providing financial information. Additionally, students 

who “have left home due to an abusive family environment” 

can choose not to provide financial information, but will have 

to contact school financial aid administrators to “complete 

the FAFSA.” Not only does this leave out students who are 

currently living in an abusive environment or who lack 

documentation of their circumstances, it also places an 

enormous burden on students in vulnerable situations to 

contact each school financial aid administrator to discuss 

their circumstances.

Across the board, students with negative—but not 

documented as abusive—relationships with their parents 

currently have no opportunity to indicate that they may be 

candidates for a dependency status override. There is also no 

information on the FAFSA that acknowledges their 

circumstances or permits omission of parental information, 

nor is there information that explains the process of obtaining 

a dependency status override.

This policy places an enormous burden on students in 

unstable situations, and cuts them off from access to more 

than the promise of an invaluable educational opportunity. 

For many, it also means cutting off the potential for future 

Forwarded 

to 

appropriate 

business 

unit. 

This comment has been forwarded to the 

appropriate business unit that reviews policy 

recommendations. 
As of 10/22/2013 7:44 PM Page | 55

Comment Status Resolution 

shelter, health care, and escape from an abusive community 

or environment.

Among the many students in situations where the pursuit of 

higher education is a point of negative interaction with their 

parents are:

Female students in families whose parents do not believe 

higher education is appropriate for women.

Religious students whose parents either do not believe in 

higher education or who would only approve of attendance at 

specific religious institutions.

LGBT students whose parents would refuse to support them if 

they came out, both at home or at school.

Students who are not yet homeless, but whose parents have 

indicated that they will not support them after high school.

Recommended Change

Individuals in these and other similar situations should not 

have to manage the burden of reaching out to the financial 

aid administrator at each school to explain their situation and 

provide differing documentation for a dependency status 

override that is subject to the professional judgment of each

administrator. In furtherance of the President’s belief in 

higher education as a gateway opportunity, the Department 

of Education should relieve students in unstable situations 

from the burden of navigating this process without 

assistance. This can be achieved by recognizing more 
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Comment Status Resolution 

circumstances under which parental information need not be 

provided, and by providing more transparent information 

about the dependency status override process that is readily 

available to students filling out the FAFSA.

In the long-term, we urge the Department of Education to 

revisit this policy in favor of a more consumer-friendly 

approach that gives all students a fair and equal opportunity 

to have their circumstances considered in the financial aid 

process.

87) Question #16. What is your marital status as of today? –

Suggestion: Change the first response option from “I am 

single” to “I have never been married” so that the wording is 

comparable to marital status options for parents in #59.

Resolved.

No Change.

88) Question #31. Are you interested in being considered for 

work-study? – Suggestion: In the Instructions section, add an 

explanation of what work-study is, such as “on- or off-campus 

student employment.”

Resolved. 

No Change.

The Department of Education considers this 

suggestion a stylistic preference.

89) Questions #37 and #86. Enter your/your parents’ income tax 

for 2013. – Suggestion: Students and parents have many 

questions about taxes paid, especially if the student/family 

has not completed their tax return or needs to estimate taxes 

paid. Many enter the “tax withheld” amount from the W-2. 

Instead, provide clearer direction on the difference between 

"taxes paid" on the tax return and "tax withheld" on the W-2 

– especially for those who are estimating their income and 

taxes paid. 

Resolved. 

No Change.

The Department of Education believes that the 

guidance in this section of the FAFSA is 

adequate.

90) For FOTW, build in an "estimated tax paid" calculator that 

looks at estimated income, number of exemptions, standard 

deduction, and standard tax rates. This could be very helpful 

to families that complete the application with estimated 

information.

Resolved. Changes made during the 2013-2014 FAFSA 

cycle provide more specific guidance to 

applicants on how to estimate their tax 

information.
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Comment Status Resolution 

91) Question #44d. Student’s Additional Financial Information –

taxable student grant and scholarship aid – Suggestion: Add 

the comment, “Consult your tax advisor.”

Resolved. 

No Change.

The Department of Education considers this 

suggestion a stylistic preference. 

92) Step Three (Student) – Suggestion: Change the heading by 

adding “Information” to the parenthetical phrase, as in 

“(Student Information).”

Resolved. 

No Change

The Department of Education considers this 

suggestion a stylistic preference.

93) Step Four (Parent) – Suggestion: Change the heading by 

adding “Information” to the parenthetical phrase, as in 

“(Parent Information).”

Resolved. 

No Change

The Department of Education considers this 

suggestion a stylistic preference.